London’s New Red Ring – The Housing Delivery Test Kicks in

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The housing delivery test results for 2020 have been announced. This is the first year in which the additional ‘presumption’ and not just action plan applies.

The results implement the new standard method, though not it seems the 25 authority uplift (I stand to be corrected on this but it is not mentioned in the document).

There are two striking geographical patterns in the results. Firstly the ‘naughty step’ authorities are strongly land constrained. Coastal, islands, penninsulas, next to national parks, small urban authorities etc. as well as of course Green Belt . This is most striking in a ‘red ring’ around London, south Essex, Kent Thames Estuary and the Push Authorities, as well as some in Greater Manchester.

The second pattern is those easily overshooting the delivery targets, in many cases by 150, 200, 250% or more. What this shows is that away from the most land or policy constrained areas with or without up to date local plans LPAs are having little difficulty in delivery. Ad Hoc sites such as those delivered under the NPPF presumption are delivering.

Overall this shows that the cause of the ‘Housing Gap’ is principally that housing targets are too low because of the 40% cap in the standard method rather more than problems of land constraint. Transferring away from these rural areas is simply piling up problems in the most land constrained and hardest to deliver authorities. Although this is not a measure of 5 year supply most authorities would not have had significant problems in meeting some increase from relaxation of the cap. In other words the conservative revolt of the shires was just wailing, of the predictable type you get say whenever reform of council tax is mentioned. Moaning nimbyism and unjustified. Of course if they don’t have up to date local plans and relay on bad presumption in favour sites that is a problem of their own making.

How might the ‘presumption’ authorities be affected by decision taking? It is similar the ‘double presumption’ that applied prior to PPG3 where a plan is out of date in housing terms an additional ‘presumption’ applies. Two qualifiers. Firstly as with the presumption overall footnote 6 authorities are exempt.

Otherwise one of two situations apply.

Firtly if a plan is out of date there is a double presumption. So the presumption might apply even if there is a 5 year supply.

Secondly even if a plan is up to date and so has a 5 year supply it can be deemed out of date in housing terms, and so the presumption applies. (para 11d and footnote 7).

In practice how many lpas have up to date plans and are not delivering? The whole point of the test. Not many none jump out at me. It requires a detailed xref which im sure nat litch or someone will do shortly. The problems of underdelivery seem concentrated in authorities without local plans and constrained areas. Which makes you think is the HDT mispecified, it isnt tacking the root causes of the housing gap, targets too low, lack of up to date local plans and land constraints in high demand areas.

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